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Child resistance

What triggers child resistance

Updated

On this page8
The regulation does not ask what your product is. It asks what is in it, and how much.

The structure of the rule

16 CFR 1700.14(a) lists substances the Commission has determined are hazardous to children by reason of their packaging, and for each one gives a threshold and a cross-reference to the standard in 1700.15. There is no fragrance category on the list, which is exactly why makers in this trade miss it.

Methyl salicylate, over 5 percent by weight

Liquid preparations above that figure, other than those in pressurized spray containers, must be in special packaging. Wintergreen and sweet birch oils are predominantly methyl salicylate, so a blend using either as a main note can clear 5 percent without anybody intending it.

Hydrocarbons, 10 percent or more

Paragraphs (a)(31) and (a)(32) catch nonemulsion liquid household products containing 10 percent or more hydrocarbons by weight with a viscosity under 100 SUS at 100 F. One applies to hazardous substances under the FHSA, the other to drugs and cosmetics under the FDCA.

What counts as a hydrocarbon

The rule defines it narrowly: substances consisting solely of carbon and hydrogen. For products with several, the percentage is the sum of the individual components by weight. Isoparaffins and mineral oil count; a glycol, which carries oxygen, does not.

Lamp and lantern fuel has its own paragraph

Paragraph (a)(7) covers prepackaged liquid kindling and illuminating preparations, naming fuel for decorative lanterns, at 10 percent or more petroleum distillates with a viscosity under 100 SUS. If you sell anything meant to be burned, read that one directly.

Do the arithmetic before the artwork

Every one of these is a number you can compute from your own formula sheet in an afternoon. Discovering it after bottles, closures and labels are bought is the expensive way to learn the same fact.

Read the paragraph that applies to you

The list runs to 33 entries and each has its own threshold, its own exemptions and its own cross-reference into the standard. Summaries, this one included, exist to tell you which paragraph to open rather than to stand in for having opened it.

References

16 CFR 1700.14, Substances requiring special packaging, under the Poison Prevention Packaging Act regulations. Paragraph (a)(3) covers liquid preparations over 5 percent methyl salicylate; (a)(7) illuminating preparations at 10 percent petroleum distillates; (a)(31) and (a)(32) hazardous substances, and drugs and cosmetics, at 10 percent or more hydrocarbons by weight and under 100 SUS at 100 F, each with an exemption for packages whose only non-child-resistant access is a spray device. law.cornell.edu
Written from federal regulation, not from a formulation bench. Whether a given formula crosses a threshold in 16 CFR 1700.14 is a question about your formula, and the percentages here are the test rather than the answer. Anything on these pages is a starting point and not clearance for a specific product.